Egg producers who house hens in management systems that allow for outdoor access have been involved in a tug of war between consumer demand from a market segment that would like birds to be outside on the ground and food safety regulations that require hens to be kept away from rodents, wild birds, flies and other wild animals. The U.S. Department of Agriculture's National Organic Program Regulations require that organic eggs come from hens with outdoor access, and the USDA is considering changing the definition of outdoors to eliminate porches. If this change happens, all organic hens would have to have outdoor access on the dirt.
The Food and Drug Administration's Salmonella enteritidis rule has provisions for sampling for rodents and flies inside the layer house and prevention of contact with wild birds and wild and stray animals. Egg producers who have hens with outdoor access have been left with questions regarding where they were required to sample for Salmonella enteritidis and what steps they were required to take to exclude contact with wild birds and animals. The FDA recently issued draft guidance to address these issues and has solicited comments from the industry prior to publishing final guidance.
Four housing styles
The FDA has defined four types of housing systems that provide outdoor access for layers: indoor area with a porch; pasture containing an indoor area; indoor area with an outdoor run, attached run style; and indoor area with an outdoor run, row style. According to the FDA, "The porch is enclosed with fence material, such as poultry wire; the porch's roof can be solid or made of wire or netting. The porch's floor is often concrete, but can be dirt or grass."
In the draft guidance, the FDA considers a porch to be part of the structure of the poultry house; it must be sampled for Salmonella enteritidis as part of the bird's indoor environment. The FDA proposes that the other three outdoor access options for layers are not subject to required Salmonella enteritidis sampling.
Stray/wild birds and animals
The Salmonella enteritidis rule requires that stray poultry, wild birds, cats and other animals be prevented from entering the poultry house. This means that these animals and birds must be prevented from entering porches, since these are considered part of the poultry house. The FDA's proposed guidance says that all stray and/or wild birds and animals do not have to be kept out of outdoor access areas that are not part of the poultry house at all times. Having said this, the FDA then says that producers are still responsible for keeping their layers Salmonella enteritidis-free, and that minimizing contact with stray and/or wild birds and animals is an important part of preventing Salmonella enteritidis introduction into the flock.
Fencing and netting requirements
The FDA's proposed guidance doesn't specify the type of fence or netting required on the sides or top of an outdoor access area for hens. Instead, the guidance says that it should be effective and leaves the selection of the materials and design up to the producer.
After listening to the FDA's question and answer session with producers, one could envision free-range hens in a pasture with no fence on the sides or enclosure material overhead meeting the Salmonella enteritidis rule requirements, as long as there weren't any wild/stray animals or birds present. But, the indoor nesting area would still be subject to Salmonella enteritidis environmental sampling, and the same rules for diverting eggs when a Salmonella enteritidis environmental positive is found would apply, as it does for birds confined to a house all of the time. The need to prevent contact with stray/wild birds and animals is important for controlling predation of the hens as well as for Salmonella enteritidis control, so design and placement of pastures should be considered in light of the need to protect birds from the sides and overhead.
Despite the seeming laissez faire approach from the FDA regarding the means used to exclude wild/stray birds and animals from outdoor access areas for layers, the agency then states that, "The presence of wild birds in an outdoor access area indicates that this route of exposure of the flock to Salmonella enteritidis is not adequately controlled." So producers can do as little or as much as they want to exclude the stray/wild birds and animals, just as long as there aren't any, and if there are, prompt additional action needs to be taken.
Monitoring for flies and rodents
Producers are not required to monitor for flies and rodents or sample for Salmonella enteritidis in outdoor access areas that aren't porches. However, the FDA does give guidance on how to do the sampling and monitoring if a producer chooses to do them. The FDA also encourages producers to monitor fly and rodent populations in outdoor access areas and to take appropriate steps to control them to prevent the introduction of Salmonella enteritidis into the flock.
Producers should take rodent and fly control in outdoor access areas just as seriously as they do inside the layer house, since it is more difficult to exclude pests from outdoor access areas. It may be more problematic to reduce numbers once a population of these pests is present. As egg producers with hens that go outdoors work to make sure they are in compliance with the Salmonella enteritidis rule, they should always remember that keeping the flock Salmonella enteritidis- negative is the ultimate goal of their efforts, not just staying compliant with regulations.
